Privacy Policy

How we use your information

This privacy notice tells you what to expect when Naim Audio Ltd (Naim Audio) collects personal information. It applies to information we collect about:

visitors to our websites;

product registrations (electronic/paper);

complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry;

people who use our services, e.g. who subscribe to our newsletter or request a publication or enquire about our services;

Naim Audio app usage;

contributors to our forum;

customer reviews;

people requiring support and service;

people who notify under the Data Protection Act; and

job applicants and our current and former employees.

This Privacy Policy relates to our online services available via our website at https://www.naimaudio.com/ (website), our mobile application The Naim App (smart device app) and any of our other online or mobile products, content and services from time to time (collectively, the Service).

This privacy policy addresses information provided to Naim Audio. In the event that Naim Audio engages with a third-party service provider, to whom we may pass your personal information or to whom you may be expected to provide your personal information, your information will be handled by that third-party service provider as if it were being handled by Naim Audio. This may include but not be limited to external training organisations, external auditing organisations, external certification organisations, external personnel benefits advisers and statutory authorities i.e. HSE. Exceptions to this arrangement are specifically stated within this privacy policy.

Please also read our Terms of Use, which govern your use of the Service.
By using the Service, you consent to the collection, storage and use of your personal information as described below. If you do not agree to this Privacy Policy, please do not use the Service and (where applicable) please uninstall the relevant application.

Data Protection Compliance

The Service is controlled by us from our offices in the United Kingdom (UK). Personal information collected from the Service is processed in accordance with the Data Protection Act 1998 (the Act) and the General Data Protection Regulation (GDPR), which regulates the processing of personal data in the UK. We comply with UK and GDPR data protection and privacy laws.

If you choose to use the Service from outside the UK, you do so at your own risk, with the understanding that personal information collected from the Service may be collected, stored and used in a country whose privacy laws may be different and less protective than those of your home country.

Visitors to our websites

When you browse this website, you do so anonymously, unless you have previously indicated that you wish Naim Audio to remember your personal information or login and password. We use a third-party service, Google Analytics, to collect standard Internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Visitors to our forum

If you register to participate on our discussion forum your information will be held by third party service provider, Hoop.La.

Use of cookies

Naim Audio use cookies on our web site to enhance the experience of users and to try to show appreciation to repeat and returning users. You can read more about how we use cookies on our Cookies Policy page.

eCommerce and Online Purchases

When you order products online via www.naimaudio.com or www.naimrecords.com we will process transaction-related personal data, such as your first and last name, mailing and shipping address, phone number and email address. We will also process information about your purchases with us.
We will use such personal data to process and deliver your order, to provide notification of order status, and to update your profile periodically to ensure that we have the most accurate personal data available. We will also use said personal data to analyse customer behaviour and to customise our communication with you, if applicable.

If you opt-in (or upon request), we will send you promotional and marketing emails. These may be targeted to you based on your purchase history or online browsing behaviour.

For the protection of Naim Audio and others we release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Conditions of Use and other agreements; or protect the rights, property or safety of Naim Audio, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. This does not include selling, renting, sharing or otherwise disclosing personally identifiable information from customers for commercial purposes in a way that is contrary to the commitments made in this Privacy Notice.

Transactions for records purchased from Naim Records will be handled by a third party provider, Bleep Stores.

Other than as set out above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information.

All external transmissions of personal data facilitated by us are protected by encryption. Processing of personal data will take place in accordance with applicable legislation and best practices concerning data security.

We use Sage Pay, an approved service provider, to collect and process transaction information.

Mobile Applications

When you download and use Naim Audio’s mobile applications, we automatically collect information on the type of device you use, operating system version, device status and the device identifier to provide and improve our mobile applications.

Some of our mobile applications collect location-based information subject to explicit consent. We will only share this information with our mapping provider for the sole purpose of mapping customer location. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at datacontroller@naimaudio.com.

We use mobile analytics software to allow us to better understand the functionality of our mobile applications installed on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We link the information we store within the analytics software to personally identifiable information you submit within the mobile application for debugging purposes.

Newsletter

We use a third-party provider, Campaign Monitor, to deliver our monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Campaign Monitor’s privacy notice.

Security and performance

Naim Audio uses a third-party service, Concrete Gong, to help maintain the security and performance of Naim Audio website. To deliver this service it processes the IP addresses of visitors to Naim Audio website.

People who Telephone Us

For customers who call Naim Audio’s service centre to use the customer support service or service desk, we use a third party provider, TMTI Ltd.

When you call Naim Audio by telephone we collect Calling Line Identification (CLI) information and record all telephone calls. We use this information to help improve its efficiency and effectiveness.

We will collect and handle that information for as long as is necessary to ensure the support has been given effectively. If the caller is a registered customer, the data will be handled in accordance with our policy on handling customer data. If not, the information will be retained for 6 months from the date of the call.

People who Email our Support Desk

For customers who email Naim Audio’s support desk information is hosted by a third party supplier, Freshworks Inc.

We will collect and handle that information for as long as is necessary to ensure the support has been given effectively. If the caller is a registered customer, the data will be handled in accordance with our policy on handling customer data. If not, the information will be retained for 6 months from the date of the call.

People who email us

We use Transport Layer Security (TLS) to encrypt and protect email. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

People who make a complaint to us

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not identify any complainants unless the details have already been made public.

People who request a product demonstration

If you request a product demonstration through our website your contact details will be passed to your nearest retailer, who will contact you to arrange an appointment.

People who use Naim Audio services

Naim Audio offers various services to the public. We use a third party to deal with some publication requests, but they are only allowed to use the information to send out the publications.

We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have used our services to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this. The procedure to follow to cancel a contract is detailed within the contract.

Service providers reporting a breach

Public electronic communications service providers are required by law to report any security breaches involving personal data to Naim Audio. If we are advised of any breach that affects the data that we hold about you, we will inform you as soon as possible, and at least within 48 hours.

Job applicants, current and former Naim Audio employees

Naim Audio is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information, please contact us at Hr@naimaudio.com

What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You do not have to provide what we ask for, but it might affect your application if you do not.

Application stage
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

You will also be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way that can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

Shortlisting
Our hiring managers shortlist applications for interview. They will be provided with your name and contact details.

Assessments
We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test, or we might take interview notes. This information is held by Naim Audio.

If you are unsuccessful following assessment for the position you have applied for, your details will not be retained.

Conditional offer
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer.

We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

Proof of your identity – you will be asked to attend our office with original documents, we will take copies. For your convenience, this will be done at the interview.

Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.

We will contact your referees, using the details you provide in your application, directly to obtain references.

We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work.
If we make a final offer, we will also ask you for the following:

Bank details – to process salary payments

Emergency contact details – so we know who to contact in case you have an emergency at work

Personnel record form.

Post start date
Our Code of Conduct requires all staff to declare if they have any potential conflicts of interest. If you complete a declaration, the information will be held on your personnel file.

Use of data processors
Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

HR Records
If you accept a final offer from us, some of your personnel records will be held on Cascade Human Resources Ltd which is an internally used HR records system.
Here is a link to their Privacy Notice: Http://www.octopus-hr.co.uk/cookies.aspx

Pensions
Likewise, your details will be provided to Scottish Widows who are the administrators of the company pension scheme, of which Naim Audio is a member organisation. You will be auto-enrolled into the pension scheme and details provided to Scottish Widows will be your name, date of birth, National Insurance number, salary and bank details.

Employee Assistance Programme
Bupa provide our Employee Assistance Programme. Within your welcome pack you will be given details of this programme.

The information you provide will be held by Bupa, who will provide you with support.

Online Testing of Personnel
The Colour Works provide online testing for us. If we ask you to complete one of these tests, we will send you a link to the test. Your answers will be provided to and held by The Colour Works.

Recruitment
For vacancies, we sometimes advertise through recruitment agencies who will collect the application information and might ask you to complete a work preference questionnaire which is used to assess your suitability for the role you have applied for, the results of which are assessed by the recruiters. Information collected will be retained for 12 months following the end of our agreement.

If you require to see the specific privacy policy of the recruitment agency handling your application, please contact HR@naimaudio.com.

For how long is the information retained?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will not be retained.

Information generated throughout the assessment process, for example interview notes, is retained by us along with all other recruitment records.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

How we make decisions about recruitment?
Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.

The Colour Works online testing is marked and a result is generated automatically. However, if you wish to challenge the mark you have received, the result can be checked manually.

You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing HR@naimaudio.com

Secondments
We also offer opportunities for people to come and work with us on a secondment basis. We accept applications from individuals or from organisations who think they could benefit from their staff working with us.

Applications are sent directly to Naim Audio. Once we have considered your application, if we are interested in speaking to you further, we will contact you using the details you provided.
We might ask you to provide more information about your skills and experience or invite you to an interview.

If we do not have any suitable work at the time, we will let you know but we might ask you if you would like us to retain your application so that we can proactively contact you about possible opportunities in the future. If you say yes, we will keep your application for 6 months.

Also, you will be expected to adhere to a confidentiality agreement and code of conduct which will be agreed with your organisation.

We ask for this information so that we fulfil our obligations to avoid conflicts of interest and to protect the information we hold.

It will be retained for the duration of your secondment plus 6 years following the end of your secondment.

Your rights

Under the Data Protection Act 1998 and the General Data Protection Regulation (GDPR), you have rights as an individual which you can exercise in relation to the information we hold about you.

Complaints or queries

Naim Audio tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Naim Audio’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body that oversees data protection law – www.ico.org.uk/concerns.

Access to personal information

Naim Audio tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Act or the Regulation. If we do hold information about you, we will:

give you a description of it;

tell you why we are holding it;

tell you to whom it could be disclosed; and

let you have a copy of the information in an intelligible form.

To make a request to Naim Audio for any personal information we may hold you need to put the request in writing addressing it to our compliance department or by writing to the address provided below.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the compliance department.

Disclosure of personal information

In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
You can also get further information on:

agreements we have with other organisations for sharing information;

circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymized statistics;

our instructions to staff on how to collect, use and delete personal data; and

how we check that the information we hold is accurate and up to date.

Links to other websites

Children's Online Privacy Protection

Naim Audio does not knowingly collect personal information from persons who are under 16 years of age. By agreeing to use our products or services, you represent that you are 16 years or older.

Links from our websites

Some pages of our websites contain external links. You are advised to verify the privacy practices of such other websites. We are not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide personal information, without assuring yourselves of the privacy practices of other websites.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 15th May 2018.